People of the Philippines Vs. Alberto L.

Mahinay

January 20, 2009

Ruling:

Either way, this Court has observed in numerous cases that lust does not respect either
time or place. The evil in man has no conscience -- the beast in him bears no respect for
time and place, driving him to commit rape anywhere, even in places where people
congregate such as in parks, along the roadside, within school premises, and inside a house
where there are other occupants.

Neither do we find merit in Mahinay’s insistence that AAA’s failure to report the incident
immediately was tantamount to giving consent to the alleged act of Mahinay. Delay in
revealing the commission of rape is not an indication of a fabricated charge. Many victims
of rape never complain or file criminal charges against the rapist, for they prefer to silently
bear the ignominy and pain, rather than reveal their shame to the world or risk the
offender’s making good his threats.

As correctly argued by the appellee, the fact that AAA did not shout or make an outcry
when there were nearby persons does not mean that she was not raped by Mahinay. The
workings of the human mind under emotional stress are unpredictable; people react
differently in such situations: some may shout; some may faint; some may be shocked into
insensibility; others may openly welcome their intrusion.

As furthermore testified to by Mahinay himself, he left his residence after he had been
accused of raping AAA, and stayed in the house of his father in Tabunok. It is settled that
the flight of an accused is an indication of his guilt or of a guilty mind.

Supreme Court Circulars on Jurisdiction — Re: Comprehensive Agrarian

Reform Program (CARP)

1.      Office of Court Administrator (OCA) Circular No. 79-2003,

June 12, 2003. Utmost Caution, Prudence and Judiciousness in the
issuance of Temporary Restraining Order and Writs of Preliminary
Injunction by Justice Presbetero J. Velasco;
 2.      Office of Court Administrator Circular (OCA) No. 23, 2004
dated Feb. 13, 2004 by Justice Presbetero J. Velasco — Reiteration
of Circular Regarding Temporary Restraining Order, Writs of
Preliminary Injunction  Prohibition and Mandamus over cases under
CARP.

3.      Adm. Circular No. 38, 2002 by Chief Justice Hilario G.

Davide — Implementation of Sec. 68, RA 6657 on Immunity of
Government  Agencies from Undue Interference — No injunction,
restraining order, prohibition or mandamus shall be issued by lower
courts, against DAR, DENR and DOJ in the implementation of the
CARP.

4.      Adm. Circular No. 29-2002 — Avoidance of Conflict of

Jurisdiction over cases under the Comprehensive Agrarian Reform
Law.

F. We do not agree with petitioner's submission that the SAC erred in

assuming jurisdiction over respondent's petition for determination of just
compensation despite the pendency of the administrative proceedings before
the DARAB. In Land Bank of the Philippines v. Court of Appeals, the
landowner filed an action for the determination of just compensation without
waiting for the completion of the DARAB's re-evaluation of the land. The
court nonetheless held therein that the SAC acquired jurisdiction over the
action for the following reason.

It is clear from Sec. 57 that the RTC, sitting as a Special Agrarian Court, has
'original and exclusive jurisdiction over all petitions for the determination of just
compensation to landowners'. This 'original and exclusive jurisdiction of the RTC
would be undermined if the DAR would vest in administrative officials original
jurisdiction in compensation cases and make the RTC an appellate court of the
review of administrative decision. Thus, although the new rules speak of directly
appealing the decision of adjudicators to the RTCs sitting as Special Agrarian
Courts, it is clear from Sec. 57 that the original and exclusive jurisdiction to
determine such cases is in the RTCs. Any effort to transfer such jurisdiction to the
Adjudicators and to convert the original jurisdiction of the RTCs into appellate
jurisdiction would be contrary to Sec. 57 and therefore would be void., Thus, direct
resort to the SAC by private respondent is valid.
 It would be well to emphasis that the taking of property under R.A. No. 6657 is an
exercise of the power of eminent domain by the State. The valuation of property or
determination of just compensation in eminent domain proceedings is essentially a
judicial function which is vested with the courts and not with administrative
agencies. Consequently, the SAC properly took cognizance of respondent's petition
for determination of just compensation. (LBP vs. LEONILA P. CELADA, G.R.
CASE NO. 164876, January 23, 2006).

People of the Philipines Vs. Roberto Abay

G.R. No. 177752 February 24, 2009

Ruling:

Under Section 5(b), Article III of RA 7610 in relation to RA 8353, if the victim of sexual abuse is below 12
years of age, the offender should not be prosecuted for sexual abuse but for statutory rape under Article
266-A(1)(d) of the Revised Penal Code and penalized with reclusion perpetua. On the other hand, if the
victim is 12 years or older, the offender should be charged with either sexual abuse under Section 5(b)
of RA 7610 or rape under Article 266-A (except paragraph 1[d]) of the Revised Penal Code. However, the
offender cannot be accused of both crimes for the same act because his right against double jeopardy
will be prejudiced. A person cannot be subjected twice to criminal liability for a single criminal act.
Likewise, rape cannot be complexed with a violation of Section 5(b) of RA 7610. Under Section 48 of the
Revised Penal Code (on complex crimes), a felony under the Revised Penal Code (such as rape) cannot
be complexed with an offense penalized by a special law.

In this case, the victim was more than 12 years old when the crime was committed against her. The
Information against appellant stated that AAA was 13 years old at the time of the incident. Therefore,
appellant may be prosecuted either for violation of Section 5(b) of RA 7610 or rape under Article 266-A
(except paragraph 1[d]) of the Revised Penal Code. While the Information may have alleged the
elements of both crimes, the prosecution’s evidence only established that appellant sexually violated
the person of AAA through force and intimidation by threatening her with a bladed instrument and
forcing her to submit to his bestial designs. Thus, rape was established.

People of the Philippines Vs. Romeo Bandin

G.R. No. 176531 April 24, 2009

Ruling:

In this case, we find no reason to overturn the conclusion arrived at by the trial court as affirmed by the
CA. It held that AAA's testimony was credible as she delivered her testimony in a clear, direct and
 positive manner. Through his voice, she positively identified appellant as the man who sexually abused
her. Identification of an accused by his voice has been accepted, particularly in cases where, as in this
case, the victim has known the perpetrator for a long time.

Consequently, appellant's defense of denial and alibi must crumble in the face of AAA's positive and
clear identification of him as the perpetrator of the crime. Denial and alibi cannot be given greater
evidentiary value than the testimonies of credible witnesses who testify on affirmative matters. Positive
identification destroys the defense of alibi and renders it impotent, especially where such identification
is credible and categorical.

People of the Philippines Vs. Armando Padilla

G.R. No. 167955 September 30, 2009

Ruling:

It is clear from the Information that AAA was alleged to be a minor who was aged eleven (11) at the time
of the commission of the crime and that the accused is her father. Contrary to the prosecution's
asseveration, it does not matter that the private complainant's relationship with the accused was
denominated as an "aggravating circumstance" and not as a "special qualifying circumstance."

The Court has repeatedly held, even after the amendments to the Rules of Criminal Procedure took
effect, that qualifying circumstances need not be preceded by descriptive words such as "qualifying" or
"qualified by" to properly qualify an offense. The Court has repeatedly qualified cases of rape where the
twin circumstances of minority and relationship have been specifically alleged in the Information even
without the use of the descriptive words "qualifying" or "qualified by." In the instant case, the fact that
AAA's relationship with appellant was described as "aggravating" instead of "qualifying" does not take
the Information out of the purview of Article 335 of the Revised Penal Code (RPC ), as amended by
Section 11 of Republic Act No. 7659 (RA 7659), which was the prevailing law at the time of the
commission of the offense. Article 335 does not use the words "qualifying" or "aggravating" in
enumerating the circumstances that qualify rape so as to make it a heinous crime punishable by death.
It merely refers to the enumerated circumstances as "attendant circumstances." The specific allegation
of the attendant circumstances in the Information, coupled with the designation of the offense and a
statement of the acts constituting the offense as required in Sections 8 and 9 of Rule 110, are sufficient
to warn appellant that the crime charged is qualified rape punishable by death.

In the present case, the attendant circumstances of minority and relationship were specifically alleged in
the Information. These allegations are sufficient to qualify the offense of rape.

As to AAA’s relationship with appellant, the Court agrees that the prosecution was able to prove it
beyond reasonable doubt. The Information alleged that appellant is the father of AAA. Appellant, in
turn, admitted during trial that AAA is her daughter. Under prevailing jurisprudence, admission in open
court of relationship has been held to be sufficient and, hence, conclusive to prove relationship with the
victim.
 However, with respect to AAA's minority, the settled rule is that there must be independent evidence
proving the age of the victim, other than the testimonies of the prosecution witnesses and the absence
of denial by appellant. The victim's original or duly certified birth certificate, baptismal certificate or
school records would suffice as competent evidence of her age. In the instant case, aside from the
testimonies of prosecution witnesses, coupled with appellant's absence of denial, no independent
substantial evidence was presented to prove the age of AAA. Neither was it shown by the prosecution
that the said documents had been lost, destroyed, unavailable or were otherwise totally absent.

Anent appellant’s failure to object to the testimony of AAA, regarding her age, the Court has held that
the failure of the accused to object to the testimonial evidence regarding the rape victim’s age shall not
be taken against him. Even the appellant's implied admission of the victim's age, in the absence of any
supporting independent evidence, may not be considered sufficient to prove her age. In People v. Biong,
the appellant testified as to the exact date when her daughter, the complainant, was born. However, the
Court held that appellant's testimony falls short of the quantum of proof required to establish her age.
As the qualifying circumstance of minority alters the nature of the crime of rape and increases the
penalty thereof, it must be proved with equal certainty and clearness as the crime itself. In the present
case, the Court agrees with appellant that the prosecution failed to discharge this burden.

The Court finds it incredible for private complainant to trump up a charge of rape against appellant on
the simple reason that she has a grudge against the latter or that she was influenced by her aunt who
harbors resentment against him. No woman would cry rape, allow an examination of her private parts,
subject herself to humiliation, go through the rigors of public trial and taint her good name if her claim
were not true.

People of the Philipines Vs. Elmer Baldo

G.R. No. 175238 February 24, 2009

Ruling:

The "sweetheart theory" or "sweetheart defense" is an oft-abused justification that rashly derides the
intelligence of this Court and sorely tests our patience. For the Court to even consider giving credence to
such defense, it must be proven by compelling evidence. The defense cannot just present testimonial
evidence in support of the theory, as in the instant case. Independent proof is required -- such as tokens,
mementos, and photographs. There is none presented here by the defense.

Moreover, even if it were true that they were sweethearts, a love affair does not justify rape. As wisely
ruled in a previous case, a man does not have the unbridled license to subject his beloved to his carnal
desires.

AAA’s failure to shout or to tenaciously resist appellant should not be taken against her since such
 negative assertion would not ipso facto make voluntary her submission to appellant’s criminal act. In
rape, the force and intimidation must be viewed in the light of the victim’s perception and judgment at
the time of the commission of the crime. As already settled in our jurisprudence, not all victims react the
same way. Some people may cry out, some may faint, some may be shocked into insensibility, while
others may appear to yield to the intrusion. Some may offer strong resistance while others may be too
intimidated to offer any resistance at all. Moreover, resistance is not an element of rape. A rape victim
has no burden to prove that she did all within her power to resist the force or intimidation employed
upon her. As long as the force or intimidation is present, whether it was more or less irresistible is
beside the point. In this case, the presence of a fan knife on hand or by his side speaks loudly of
appellant’s use of violence, or force and intimidation.

Compilation on Jurisprudence on Rape

From years 2000-2009

2009
  

People of the Philippines Vs. Ruben Corpuz

G.R. No. 175836 January 30, 2009

Ruling:

In People v. Adajio, the Court found that fear of bodily harm and fear for the safety of her family
prevented the therein complainant from shouting for help, caused her to spread her legs upon the order
of her rapist, and compelled her to follow him to the place where the second charge of rape occurred. It
thus held that physical resistance need not be established in rape when threats and intimidation are
employed and the victim submits herself to the embrace of her rapist because of fear, as in the cases at
bar.

The effects of threats and intimidation aside, appellant being the common-law spouse of AAA’s mother
BBB, moral ascendancy substituted for intimidation. Indeed, in rape committed by a close kin, such as
the victim's father, stepfather, uncle, or the common-law spouse of her mother, it is not necessary that
actual force or intimidation be employed; moral influence or ascendancy takes the place of violence or
intimidation.

As for the appellate court’s characterization of the crime as simple rape, the Court finds the same to be
consistent with Article 266-B of the Revised Penal Code and settled jurisprudence that, to obtain a
conviction for qualified rape, the minority of the victim and her relationship to the offender must be
both alleged in the Information and proved with certainty. In the present cases, AAA’s minority was
alleged and proved, the same having been averred in each of the Informations and proven by a
certification from the Office of the Civil Registrar of Kabugao, Apayao as to AAA’s date of birth.

The supposed stepfather-stepdaughter relationship between appellant and AAA, on the other hand, was
alleged in each of the Informations. The stepfather-stepdaughter relationship as a qualifying
circumstance presupposes that the victim’s mother and the accused contracted marriage. The
prosecution, however, did not present proof that BBB and appellant did contract marriage. What
appellant claimed is that he and BBB are merely common-law spouses ("live-in" partners), which could
also qualify the offense but only if the same is alleged in each of the Informations and proven at the
trial. The appellate court thus correctly held that appellant committed six (6) counts of simple rape.

JURISPRUDENCE ON JURISDICTION OVER AGRARIAN CASES

 
1. BETWEEN MTC AND CAR (Now DARAB)

A. AGUSTIN RIVERA VS. NEMESIO DAVID. G.R. NO. 157307; February 27,
2006

Doctrines/Features:

A. Existence of prior AGRICULTURAL TENANCY RELATIONSHIP

characterizes the controversy as an "AGRARIAN DISPUTE";

B.Sec. 21, Republic Act No. 1199 provides that "all cases involving the
dispossession of a tenant by the landlord or by a third party and/or the
settlement and disposition of disputes arising from the relationship of landlord
and tenant. . . . shall be under the original and exclusive jurisdiction of the
Court of Agrarian Relations."

B. In the case of Vda. de Arejola vs. Camarines Sur Reg. Agricultural School,
et al., 110 SCRA 517 (1960), the Supreme Court explained the phrase "by a third
party" in Section 21 of RA 1199 (Ejectment; Violation; Jurisdiction. — "all cases
involving the dispossession of a tenant by the landholder or by a third party —) The
Supreme Court held that when no tenancy relationship between the contending
parties exist, the Court of Agrarian Relations has no jurisdiction", "The law
governing agricultural tenancy, RA 1199 explains that tenancy relationship is a
"juridical tie" which arises between a landholder and a tenant once they agree
expressly or impliedly to undertake jointly the cultivation of land belonging to the
former, etc."

C. The issue of ownership cannot be settled by the DARAB since it is definitely

outside its jurisdiction. Whatever findings made by the DARAB regarding the
ownership of the land are not conclusive to settle the matter. The issue of ownership
shall be resolved in a separate proceedings before the appropriate trial court
between the claimants thereof. (Jaime Morta, Sr., et al., vs. Jaime Occidental, et al.,
G.R. No. 123417, (June 10, 1999) (Note the Dissenting Opinion of Chief Justice
Davide Jr.,)

D. Where there are no tenurial, leasehold, or any agrarian relations whatsoever

between the parties that could bring a controversy under the ambit of the agrarian
reform laws, the Department of Agrarian Reform Adjudication Board has no
jurisdiction. (Heirs of the Late Herman Rey Santos vs. CA, 327 SCRA 293).

2. BETWEEN RTC AND DAR/DARAB

DAR VS. ROBERTO CUENCA, et al., G.R. No. 154112, September 23, 2004.
A. All controversies on the implementation of the Comprehensive Agrarian
Reform Program (CARP) fall under the jurisdiction of the Department of Agrarian
Reform (DAR), even through they raise questions that are also legal or
constitutional in nature. All doubts should be resolved in favor of the DAR, since
the law has granted it special and original authority to hear and adjudicate agrarian
matter.

B. In view of the foregoing, there is no need to address the other points

pleaded by respondent in relation to the jurisdictional issue. We need only to point
that in case of doubt, the jurisprudential trend is for courts to refrain from resolving
a controversy involving matters that demand the special competence of
administrative agencies, "even if the question[s] involved [are] also judicial in
character, as in this case.

C. Having declared the RTCs to be without jurisdiction over the instant case, it
follows that the RTC of La Carlota City (Branch 63) was devoid of authority to
issue the assailed Writ of Preliminary Injunction. That Writ must perforce be
stricken down as a nullity. Such nullity is particularly true in the light of the
express prohibitory provisions of the CARP and this Court's Administrative
Circular Nos. 29-2002 and 38-2002. These Circulars enjoin all trial judges to
strictly observe Section 68 of RA 6657, which reads:

"Section 68.  Immunity of Government Agencies from Undue Interference.

— No injunction, restraining order, prohibition or mandamus shall be
issued by the lower courts against the Department of Agrarian Reform
(DAR), the Department of Agriculture (DA), the Department of
Environment and Natural Resources (DENR) and the Department of
Justice (DOJ) in their implementation of the program."

ALSO:

Supreme Court Circulars on Jurisdiction — Re: Comprehensive Agrarian

Reform Program (CARP)

1.      Office of Court Administrator (OCA) Circular No. 79-2003,

June 12, 2003. Utmost Caution, Prudence and Judiciousness in the
issuance of Temporary Restraining Order and Writs of Preliminary
Injunction by Justice Presbetero J. Velasco;

2.      Office of Court Administrator Circular (OCA) No. 23, 2004

dated Feb. 13, 2004 by Justice Presbetero J. Velasco — Reiteration
of Circular Regarding Temporary Restraining Order, Writs of
 Preliminary Injunction  Prohibition and Mandamus over cases under
CARP.

3.      Adm. Circular No. 38, 2002 by Chief Justice Hilario G.

Davide — Implementation of Sec. 68, RA 6657 on Immunity of
Government  Agencies from Undue Interference — No injunction,
restraining order, prohibition or mandamus shall be issued by lower
courts, against DAR, DENR and DOJ in the implementation of the
CARP.

4.      Adm. Circular No. 29-2002 — Avoidance of Conflict of

Jurisdiction over cases under the Comprehensive Agrarian Reform
Law.

3. BETWEEN DAR AND DARAB

A. ON ORDER OF EXECUTION ERNESTO INGLES, ET. AL. VS. COURT

OF APPEALS, ET. AL., G.R. NO. 125202, JAN. 31, 2006

Doctrines/Features:

A. Thus, the functions of the DAR Regional Director are purely

administrative, that is, to put into operation agrarian laws and fill out the
details necessary for their implementation, and not adjudicatory.

B. On the other hand, when a dispute arises between parties affected by

the operation of agrarian laws, the controversy should be settle in an
adversarial proceeding before the DARAB, the quasi judicial arm of the
DAR function becomes judicial or quasi judicial in nature when the
exercise thereof involves the determination of rights and obligations of
the parties.

C. In issuing the questioned Order of Execution, the DAR Regional

Director overstepped the limits of his office and crossed the realm of
adjudication. While the orders sought to be implemented merely
directed the survey of the areas to be excluded from the CARP, the
Order of Execution, however, included the search for a relocation site
for the benefit of farmers who would be affected by the order of
exemption and the determination of appropriate disturbance
compensation. Thus, the DAR Regional Director turned what was
supposed to be an administrative process into an adjudicatory
proceeding. The relocation of occupants is normally conducted with the
 issuance of a writ of demolition, an act which is within the competence
of the DARAB.

B.ON CANCELLATION OF EPs/CLOAs HEIRS OF JULIAN DE LA CRUZ

VS. OF ALBERTO CRUZ, G.R. NO. 162890, November 22, 2005:

Doctrines/Features:

A. The Court agrees with the petitioner's contention that, under Section
2 (f), Rule II of the DARAB Rules of Procedures, the DARAB has
jurisdiction over cases involving the issuance, correction and
cancellation of CLOAs which were registered with the LRA. However,
for the DARAB to have jurisdiction in such case, they must relate to an
agrarian dispute between landowner and tenants to whom CLOAs have
been issued by the DAR Secretary. The cases involving the issuance,
correction and cancellation of the CLOAs by the DAR in the
administrative implementation of agrarian laws, rules and regulations to
parties who are not agricultural tenants or lessees are within the
jurisdiction of the DAR and not of the DARAB

B. Section 3 (d) of R.A. No. 6657 defines an "agrarian dispute" as "any

controversy relating to tenurial arrangements, whether leasehold,
tenancy, stewardship or otherwise over lands devoted to agricultural,
including disputes concerning farmworkers' associations or
representation of persons in negotiating, fixing, maintaining, changing,
or seeking to arrange terms or conditions of such tenurial arrangements.
It includes any controversy relating to compensation of lands acquired
under this Act and other terms and condition of transfer of ownership
from landowners to farmworkers, tenants and other agrarian reform
beneficiaries, whether the disputants stand in the proximate relation of
farm operation and beneficiaries, landowner and tenant, or lessor and
lessee."

In Morta, Sr. v. Occidental (G.R. 123417, 10 June 1999, 308 SCRA

167), this Court held that there must be a tenancy relationship between
the parties for the DARAB to have jurisdiction over a case. It is
essential to establish all its indispensable elements, to wit: (1) that the
parties are the landowner and the tenant or agricultural lessee; (2) that
the subject matter of the relationship is an agricultural land; (3) that
there is consent between the parties to the relationship (4) that the
purposes of the relationship is to bring about agricultural production; (5)
that there is personal cultivation on the part of the tenant or agricultural
 lessee; and (6) that the harvest is shared between the landowner and the
tenant or agricultural lessee.

C. In Vda. De Tangub vs. Court of Appeals, we held that the

jurisdiction of the Department of Agrarian Reform is limited to the
following: a) adjudication of all matters involving implementation of
agrarian reform; b) resolution of agrarian conflicts and land-tenure
related problems; and c) approval and disapproval of the conversion,
restructuring or readjustment of agricultural lands into residential,
commercial, industrial, and other non-agricultural uses. (Morta, Sr. vs.
Occidental, 308 SCRA 167).

4. BETWEEN DARAB and SAC

A. "It is error to think that, because of Rule XIII, Section II, the
original and exclusive jurisdiction given to the courts to decide petition for
determination of just compensation has already been transformed into an
appellate jurisdiction. It only means that, in accordance with settled principle
of administrative law, primary jurisdiction is vested in the DAR as an
administrative agency to determine in a preliminary manner the reasonable
compensation to be paid for the lands taken under the CARP, but such
determination is subject to challenge in the courts.

"The jurisdiction of the Regional Trial Courts is not any less "original
and exclusive", because the question is first passed upon by the DAR,
as the judicial proceedings are not a continuation of the
administrative determination. For the matter, the law may provide
that the decision of the DAR is final and unappealable. Nevertheless,
resort to courts cannot be foreclosed on the theory that courts are the
guarantors of the legality of administrative action" (Phil. Veterans
Bank vs. Court of Appeals, G.R. No. 132767, January 18, 2000).

B.It is the DARAB which has the authority to determine the initial valuation
of lands involving agrarian reform although such valuation may only be
considered preliminary as the final determination of just compensation is
vested in the courts. (Land Bank of the Philippines vs. Court of Appeals, 321
SCRA 629).

C.Nothing contradictory between the provisions of Sec. 50, R.A. 6657

granting the Department of Agrarian Reform primary jurisdiction
(administrative proceeding) to determine and adjudicate "agrarian reform
matters" and exclusive original jurisdiction over "all matters involving the
implementation of agrarian reform" which includes the determination of
 questions of just compensation, and the provisions of Sec. 57, R.A. 6657
granting Regional Trial Courts "original and exclusive jurisdiction" (judicial
proceeding) over (1) all petitions for the determination of just compensation
to landowner, and (2) prosecutions of criminal offenses under Republic Act
No. 6657. (Philippine Veterans Bank vs. CA, 322 SCRA 139).

D. It is error to think that, because of Rule XIII, Sec. 11, the original
and exclusive jurisdiction given to the courts to decide petitions for
determination of just compensation has thereby been transformed into an
appellate jurisdiction. (Philippine Veterans Bank vs. CA, 322 SCRA 139).

E.The jurisdiction of the Regional Trial Courts is not any less "original and
exclusive" because the question is first passed upon by the DAR, as the
judicial proceedings are not a continuation of the administrative
determination. For that matter, the law may provide that the decision of the
DAR is final and unappealable. Nevertheless, resort to the courts cannot be
foreclosed on the theory that courts are the guarantors of the legality of
administrative action. (Philippine Veterans Bank vs. CA, 322 SCRA 139).

F. We do not agree with petitioner's submission that the SAC erred in

assuming jurisdiction over respondent's petition for determination of just
compensation despite the pendency of the administrative proceedings before
the DARAB. In Land Bank of the Philippines v. Court of Appeals, the
landowner filed an action for the determination of just compensation without
waiting for the completion of the DARAB's re-evaluation of the land. The
court nonetheless held therein that the SAC acquired jurisdiction over the
action for the following reason.

It is clear from Sec. 57 that the RTC, sitting as a Special Agrarian Court, has
'original and exclusive jurisdiction over all petitions for the determination of just
compensation to landowners'. This 'original and exclusive jurisdiction of the RTC
would be undermined if the DAR would vest in administrative officials original
jurisdiction in compensation cases and make the RTC an appellate court of the
review of administrative decision. Thus, although the new rules speak of directly
appealing the decision of adjudicators to the RTCs sitting as Special Agrarian
Courts, it is clear from Sec. 57 that the original and exclusive jurisdiction to
determine such cases is in the RTCs. Any effort to transfer such jurisdiction to the
Adjudicators and to convert the original jurisdiction of the RTCs into appellate
jurisdiction would be contrary to Sec. 57 and therefore would be void., Thus, direct
resort to the SAC by private respondent is valid.

It would be well to emphasis that the taking of property under R.A. No. 6657 is an
exercise of the power of eminent domain by the State. The valuation of property or
determination of just compensation in eminent domain proceedings is essentially a
judicial function which is vested with the courts and not with administrative
agencies. Consequently, the SAC properly took cognizance of respondent's petition
for determination of just compensation. (LBP vs. LEONILA P. CELADA, G.R.
CASE NO. 164876, January 23, 2006).